Here at Swan Energy we’ve been at the forefront of incorporating grid-injected biomethane into the EU ETS. Swan Energy are was one of the first to work with GNI to submit a revised Monitoring Plan incorporating grid-injected biomethane as a source stream, and we’ve since supported trials assessing both indigenous and imported biomethane against EU ETS requirements.
Biomethane is increasingly being recognised as a practical decarbonisation solution for industrial gas users operating under the EU Emissions Trading System (EU ETS). While this is an EU-wide policy framework, its application has gained particular traction in Ireland, driven by strong national decarbonisation targets and proactive industry engagement.
Under the EU ETS Monitoring and Reporting Regulation (MRR), Operators must report emissions based on fuel consumed, such as natural gas. However, where grid injected biomethane meets the required sustainability criteria under Art’ 39(3) and (4)of the MRR alongside the RED II/III and is correctly evidenced, it can be assigned an emission factor of zero. This includes:
- No double counting of the same biomethane quantity (including ensuring it is not claimed elsewhere, for example via a Guarantee of Origin (GoO))
- The Operator and producer of the biogas are connected to the same gas grid
- Full compliance with applicable sustainability and GHG savings criteria
This allows Operators the opportunity to deduct eligible biomethane volumes from their natural gas consumption, reducing both reported emissions and carbon costs.
However, the detail lies in how biomethane is procured and evidenced. For compliance, biomethane must be purchased via a Proof of Origin approach linked to a physical flow of gas through the grid. This ensures that the renewable gas being claimed is properly accounted for within the system. This is distinctly different from GoOs, which relate only to the transfer of renewable characteristics and do not meet EU ETS requirements.
To demonstrate compliance, biomethane must be supported by recognised certification schemes that verify sustainability and greenhouse gas savings on a batch-by-batch basis, such as ISCC. These schemes provide assurance that RED II/RED III criteria are met. However, the exact requirements can vary depending on factors such as the feedstock used to produce the biomethane, meaning careful assessment is needed to ensure full compliance as overall the burden of proof sits with the Operator to demonstrate that all relevant criteria have been met.
It is also worth noting that, while the Union Database (UDB) is expected to further support traceability in the future, it is not yet operational making existing certification and registry processes even more critical.
In Ireland, a key part of the audit trail involves working with Gas Networks Ireland (GNI) to obtain Renewable Natural Gas Registry (RNG Registry) Cancellation Statements. These confirm that the environmental attributes associated with the biomethane have been exclusively allocated and retired, helping to prevent double counting and supporting EU ETS compliance. However, before biomethane can be utilised as outlined above, the Monitoring Plan (MP) must first be revised to include it as a source stream, something GNI has published useful guidance on how to complete.
Here at Swan Energy we support clients in two ways: firstly, through Monitoring Plan updates and biomethane implementation, including documentation, source stream methodology, and engagement with the Competent Authority. Secondly, through full EU ETS compliance support, covering both Monitoring Plans and ongoing annual obligations such as emissions reporting and verification.
Biomethane offers a clear route to reducing EU ETS emissions, but compliance is complex. Our team brings deep expertise, strong industry relationships, and proven experience to help operators navigate this with confidence.
Click here to find out more about Biomethane and working with the Swan Energy team. If you’d like to discuss this further, please get in touch.
